Is it essential for Program leadership to ensure that all distance-education courses, including asynchronous courses, meet or exceed the requirements for regular, substantive, faculty-initiated interaction. 

Regulations

Please consider the following updated regulation for student-faculty interaction in distance education courses:  

The Department of Education made multiple amendments to the Code of Federal Regulations Chapter 34, §600.2 to address the developments in distance education, with the last update on 7/01/2022.   

Rulemaking focused on the importance of “regular and substantive interaction” that is “faculty-initiated” to distinguish “distance education” eligible for federal financial aid, from correspondence education, which is not eligible. Not following these regulations (e.g., treating asynchronous courses as correspondence courses) has severe repercussions for institutional accreditation and financial aid eligibility.  

Subsequently, WSCUC added a related prompt to the WSCUC Program Proposal Template: Describe how the program meets expectations for “Academic Engagement” and “Faculty-Initiated Regular and Substantive Interaction.” 

The regulation defines substantive interaction as “engaging students in teaching, learning, and assessment, consistent with the content under discussion” and including at least two of the following: 

1. Providing direct instruction; 
2. Assessing or providing feedback on a student’s coursework; 
3. Providing information or responding to questions about the content of a course or competency; 
4. Facilitating a group discussion regarding the content of a course or competency; or, 
5. Other instructional activities approved by the institution’s or program’s accrediting agency. 

Additionally, instructors in online courses are expected to monitor a student’s academic engagement and success and “promptly and proactively” engage with the student “when needed on the basis of such monitoring, or upon request by the student.” 

Examples and Expectations

Peer institutions provide helpful examples for meeting these requirements: 

To help meet these goals, instructors are encouraged to require at least one of the following student engagement activities within the first two weeks (the first week for 8 or 5 week courses) of the course and then routinely use at least throughout the course (at least once every two weeks). It is beneficial to go beyond minimal expectations.                                                                                                                                           

• Submitting an academic assignment; 
• Completing a quiz/check your understanding assessment or interaction that relates to the course material. (A course syllabus quiz is not sufficient.); 
• Responding to a discussion board post based on a prompt that is relevant to the course material. (A getting-to-know-you question is not sufficient.); 
• Participating in an assigned study group or group project (instructor will need to be able to show evidence of participation);
• Attending a synchronous class or lab session, in-person or online, where there is an opportunity for direct interaction between the instructor and student(s). Just logging into the LMS is not sufficient. 

Distance Education Defined

The final definition of distance education in 34 CFR 600.2 is as follows: 

Education that uses one or more of the technologies listed below to deliver instruction to students who are separated from the instructor or instructors, and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously. 

1. The internet;
2. One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
3. Audio conferencing; or
4. Other media used in a course in conjunction with any of the technologies listed in paragraphs (1)(i) through (1)(iii) of this definition.

For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by the institution’s accrediting agency. Instructors must ensure meeting the requirements for academic engagement and faculty-initiated regular and substantive interaction. 

Correspondence courses do not need to meet these requirements and are not offered at Vanguard University in any program.